concurring in part, dissenting in part.
I concur in the portion of the majority opinion which finds no successor liability. However, as I believe the majority erroneously resolves plaintiff’s substantive claims, I dissent.
I dissent for several reasons. First, after review of the entire record I am firmly convinced, that although supporting evidence exists, the court is mistaken in affirming the findings that defendant’s treatment of plaintiff evinced no anti-female animus and that gender-based discrimination played no role in her discharge. The overall circumstances of plaintiff’s workplace evince an anti-female environment. For seven years plaintiff worked at Osceola as the sole woman in a salaried management position. In common work areas plaintiff and other female employees were exposed daily to displays of nude or partially clad women belonging to a number of *624male employees at Osceola. One poster, which remained on the wall for eight years, showed a prone woman who had a golf ball on her breasts with a man standing over her, golf club in hand, yelling “Fore.” And one desk plaque declared “Even male chau-vanist pigs need love.” Plaintiff testified the posters offended her and her female co-workers.
In addition, Computer Division Supervisor Doug Henry regularly spewed anti-female obscenity. Henry routinely referred to women as “whores,” “cunt”, “pussy” and “tits.” See Rabidue v. Osceola, 584 F.Supp. 419, 423 (E.D. Mich.1984). Of plaintiff, Henry specifically remarked “All that bitch needs is a good lay” and called her “fat ass.” Plaintiff arranged at least one meeting of female employees to discuss Henry and repeatedly filed written complaints on behalf of herself and other female employees who feared losing their jobs if they complained directly. Osceola Vice President Charles Muetzel stated he knew that employees were “greatly disturbed” by Henry’s language. However, because Osceola needed Henry’s computer expertise, Muetzel did not reprimand or fire Henry. In response to subsequent complaints about Henry, a later supervisor, Charles Shoemaker, testified that he gave Henry “a little fatherly advice” about Henry’s prospects if he learned to become “an executive type person.”
In addition to tolerating this anti-female behavior, defendant excluded plaintiff, the sole female in management, from activities she needed to perform her duties and progress in her career. Plaintiff testified that unlike male salaried employees, she did not receive free lunches, free gasoline, a telephone credit card or entertainment privileges. Nor was she invited to the weekly golf matches. Without addressing defendant’s disparate treatment of plaintiff, the district court dismissed these perks and business activities as fringe benefits. After plaintiff became credit manager defendant prevented plaintiff from visiting or taking customers to lunch as all previous male credit managers had done. Plaintiff testified that upon requesting such privileges, her supervisor, Mr. Muetzel, replied that it would be improper for a woman to take male customers to lunch and that she “might have car trouble on the road.” Plaintiff reported that on another occasion, Muetzel asked her “how would it look for me, a married man, to take you, a divorced woman, to the West Branch Country Club in such a small town?” However, defendant apparently saw no problem in male managers entertaining female clients regardless of marital status. Plaintiff's subsequent supervisor, Charles Shoemaker, stated to another female worker, Joyce Solo, that “Vivienne (plaintiff) is doing a good job as credit manager, but we really need a man on that job,” adding “She can’t take customers out to lunch.” Aside from this Catch-22, Mr. Shoemaker also remarked plaintiff was not forceful enough to collect slow-paying jobs. How plaintiff can be so abrasive and aggressive as to require firing but too timid to collect delinquent accounts is, in my view, an enigma.
My review of the record also shows plaintiff was consistently accorded secondary status. Plaintiff recounted that at a meeting convened to instruct clerical employees on their duties after the United States Refineries takeover, plaintiff was seated with female hourly employees. The male salaried employees, apparently pre-in-formed of the post-takeover procedures, stood at the front of the room. Plaintiff confronted Muetzel to express surprise at being addressed as a clerical employee and to ask what her post-takeover role would entail. Muetzel responded plaintiff would have whatever role was handed to her. At the suggestion of her former boss, Mr. Hansen, plaintiff wrote a memo summarizing her qualifications and pleading for non-sex based consideration for post-takeover positions. She received no response to this memo.
In contrast to the supervisors’ reluctance to address Henry’s outrageous behavior, plaintiff was frequently told to tone down and discouraged from executing procedures she felt were needed to correct waste and improve efficiency as her job required. *625Not only did plaintiff receive minimal support, but she was repeatedly undermined. For example, supervisor Doug Henry once directed his employees to ignore plaintiffs procedures for logging time and invoices, a particularly damaging directive given plaintiffs responsibility of coordinating the work of Henry’s computer staff. In another example, plaintiff returned from her vacation to find that none of the check depositing procedures agreed upon had been implemented and that some of her duties had been permanently transferred to the male who filled in during her vacation. In contrast to the fatherly advice and the praise for potential which Henry received, plaintiff was informed she had set her goals too high. After dismissal, but prior to final notice, plaintiff received instructions not to return to the refinery. In contrast, male employees fired for embezzlement were allowed to return to clean out their desks. Upon dismissal, plaintiff reported that Shoemaker advised her to get a secretarial job.
The record establishes plaintiff possessed negative personal traits. These traits did not, however, justify the sex-based disparate treatment recounted above. Whatever undesirable behavior plaintiff exhibited, it was clearly no worse than Henry’s. I conclude the misogynous language and decorative displays tolerated at the refinery (which even the district court found constituted a “fairly significant” part of the job environment), the primitive views of working women expressed by Osceola supervisors and defendant’s treatment of plaintiff as the only female salaried employee clearly evince anti-female animus.
Second, I dissent because I am unable to accept key elements of the standard for sexual harassment set forth in the majority opinion. Specifically, I would not impose on the plaintiff alleging hostile environment harassment an additional burden of proving respondeat superior liability where a supervisor is responsible for the harm. In Meritor Savings Bank v. Vinson, — U.S. -, 106 S.Ct. 2399, 91 L.Ed.2d 49 (1986), the Supreme Court instructed courts to determine employer liability according to agency principles. Id. — U.S. -, 106 S.Ct. at 2407. Agency principles establish that an employer is normally liable for the acts of its supervisors and agents. Id. Because a supervisor is “clothed with the employer’s authority” and is responsible for the “day-to-day supervision of the work environment and with ensuring a safe, productive workplace,” his abusive behavior in violation of that duty should be imputed to the employer just as with any other supervisory action which violates Title VII. Id. — U.S. at -, 106 S.Ct. at 2410-11 (J. Marshall concurring, joined by JJ. Brennan, Blackmun and Stevens). The creation of a discriminatory work environment by a supervisor can only be achieved through the power accorded him by the employer. I see insufficient reason to add an element of proof not imposed on any other discrimination victim, particularly where agency principles and the “goals of Title VII law” preclude the imposition of automatic liability in all circumstances. Id. As Justice Marshall concludes:
There is therefore no justification for a special rule, to be applied only in “hostile environment” cases, that sexual harassment does not create employer liability until the employee suffering the discrimination notifies other supervisors. No such requirement appears in the statute, and no such requirement can coherently be drawn from the law of agency.... I would apply in this case the same rules we apply in all other Title VII cases, and hold that sexual harassment by a supervisor of an employee under his supervision, leading to a discriminatory work environment, should be imputed to the employer for Title VII purposes regardless of whether the employee gave “notice” of the offense.
Id.
In cases of hostile work environment harassment by coworkers, I would follow guidelines set forth by the Equal Employment Opportunity Commission:
With respect to conduct between fellow employees, an employer is responsible *626for acts of sexual harassment in the workplace where the employer (or its agents or supervisory employees) knows or should have known of the conduct, unless it can show that it took immediate and appropriate action.
29 C.F.R. §§ 1604.11(d) (1985).
Nor do I agree with the majority holding that a court considering hostile environment claims should adopt the perspective of the reasonable person's reaction to a similar environment. At 619. In my view, the reasonable person perspective fails to account for the wide divergence between most women’s views of appropriate sexual conduct and those of men. See Comment, Sexual Harassment Claims of Abusive Work Environment Under Title VII, 97 Harv.L.Rev. 1449, 1451 (1984). As suggested by the Comment, I would have courts adopt the perspective of the reasonable victim which simultaneously allows courts to consider salient sociological differences as well as shield employers from the neurotic complainant. Id. at 1459. Moreover, unless the outlook of the reasonable woman is adopted, the defendants as well as the courts are permitted to sustain ingrained notions of reasonable behavior fashioned by the offenders, in this case, men. Id.
Which brings me to the majority’s mandate to consider the “prevailing work environment,” “the lexicon of obscenity that pervaded the environment both before and after plaintiff’s introduction into its environs,” and plaintiff’s reasonable expectations upon “voluntarily” entering that environment. At 620. The majority suggests through these factors that a woman assumes the risk of working in an abusive, anti-female environment. Moreover, the majority contends that such work environments somehow have an innate right to perpetuation and are not to be addressed under Title VII:
Indeed, it cannot seriously be disputed that in some work environments, humor and language are rough hewn and vulgar. Sexual jokes, sexual conversations and girlie magazines may abound. Title VII was not meant to — or can — change this. It must never be forgotten that Title VII is the federal court mainstay in the struggle for equal employment opportunity for the female workers of America. But is quite different to claim that Title VII was designed to bring about a magical transformation in the social mores of American workers. Clearly, the Court’s qualification is necessary to enable 29 C.F.R. § 1604.11(a)(3) to function as a workable judicial standard.
At 620 (quoting the district court opinion, Osceola v. Rabidue, 584 F.Supp. at 430.)
In my view, Title VII’s precise purpose is to prevent such behavior and attitudes from poisoning the work environment of classes protected under the Act. To condone the majority’s notion of the “prevailing workplace” I would also have to agree that if an employer maintains an anti-semitic workforce and tolerates a workplace in which “kike” jokes, displays of nazi literature and anti-Jewish conversation “may abound,” a Jewish employee assumes the risk of working there, and a court must consider such a work environment as “prevailing.” I cannot. As I see it, job relatedness is the only additional factor which legitimately bears on the inquiry of plaintiff’s reasonableness in finding her work environment offensive. In other words, the only additional question I would find relevant is whether the behavior complained of is required to perform the work. For example, depending on their job descriptions, employees of soft pornography publishers or other sex-related industries should reasonably expect exposure to nudity, sexually explicit language or even simulated sex as inherent aspects of working in that field. However, when that exposure goes beyond what is required professionally, even sex industry employees are protected under the Act from non-job related sexual demands, language or other offensive behavior by supervisors or co-workers. As I believe no woman should be subjected to an environment where her sexual dignity and reasonable sensibilities are visually, verbally or physically assaulted as *627a matter of prevailing male prerogative, I dissent.
The majority would also have courts consider the background of plaintiffs co-workers and supervisors in assessing the presence of actionable work environment sex harassment. The only reason to inquire into the backgrounds of the defendants or other co-workers is to determine if the behavior tolerated toward female employees is reasonable in light of those backgrounds. As I see it, these subjective factors create an unworkable standard by requiring the courts to balance a morass of perspectives. But more importantly, the background of the defendants or other workers is irrelevant. No court analyzes the background and experience of a supervisor who refuses to promote black employees before finding actionable race discrimination under Title VII. An equally disturbing implication of considering defendants’ backgrounds is the notion that workplaces with the least sophisticated employees are the most prone to anti-female environments. Assuming arguendo * this notion is true, by applying the prevailing workplace factor, this court locks the vast majority of working women into workplaces which tolerate anti-female behavior. I conclude that for actionable offensive environment claims, the relevant inquiry is whether the conduct complained of is offensive to the reasonable woman. Either the environment affects her ability to perform or it does not. The backgrounds and experience of the defendant’s supervisors and employees is irrelevant.
Nor can I agree with the majority’s notion that the effect of pin-up posters and misogynous language in the workplace can have only a minimal effect on female employees and should not be deemed hostile or offensive “when considered in the context of a society that condones and publicly features and commercially exploits open displays of written and pictorial erotica at newsstands, on prime-time television, at the cinema and in other public places.” At 622. “Society” in this scenario must primarily refer to the unenlightened; I hardly believe reasonable women condone the pervasive degradation and exploitation of female sexuality perpetuated in American culture. In fact, pervasive societal approval thereof and of other stereotypes stifles female potential and instills the debased sense of self worth which accompanies stigmatization. The presence of pin-ups and misogynous language in the workplace can only evoke and confirm the debilitating norms by which women are primarily and contemptuously valued as objects of male sexual fantasy. That some men would condone and wish to perpetuate such behavior is not surprising. However, the relevant inquiry at hand is what the reasonable woman would find offensive, not society, which at one point also condoned slavery. I conclude that sexual posters and anti-female language can seriously affect the psychological well being of the reasonable woman and interfere with her ability to perform her job.
Finally, I find probative evidence supports plaintiff’s retaliation claim. Plaintiff presented substantial evidence that her supervisor Charles Shoemaker withheld her unemployment benefits because she filed a sex discrimination complaint. Joyce Solo, a co-worker, testified that right after plaintiff was fired and filed charges, Shoemaker stated he “would have let [plaintiff] have her unemployment, except she filed sex discrimination charges and it made me mad so I charged her with misconduct.” Another employee also testified that Shoemaker instructed Osceola employees to write up negative encounters with plaintiff or they might have to have her return to work. Thus, plaintiff presented evidence showing Shoemaker accorded her adverse treatment because she filed a sex discrimination charge. This is a prima facie case of retaliation which should have been addressed by the district court and not dismissed by this *628court as an “inartfully pleaded” cause of action.
In conclusion, I dissent because the record shows that defendant’s treatment of plaintiff evinces anti-female animus and that plaintiff’s gender played a role in her dismissal. I also believe the hostile environment standard set forth in the majority opinion shields and condones behavior Title VII would have the courts redress. Finally, in my view, the standard fails to encourage employers to set up internal complaint procedures or otherwise seriously address the problem of sexual harassment in the workplace.
I do not assert any correlation exists between the level of social sophistication present in a work environment and anti-female behavior.